Welcome to the bimonthly publication IRS Insights, produced by Deloitte's Tax Controversy Services Group to keep our clients abreast of current issues related to the Internal Revenue Service.
In this month's issue:
· LMSB Directive Renews the Focus on Examination of Parties in Intermediary Transaction Tax Shelters – The IRS’s Large and Midsize Business Division (LMSB) is refocusing its attention on the potential liability of all parties to intermediary transaction shelter transactions, not just the intermediary entity, the LMSB said in a memorandum for Industry Directors, LMSB staff, and the Small Business/Self-Employed Division (SB/SE). The LMSB memorandum announced a directive regarding the examination of multiple parties to these shelter transactions described in Notice 2001-16, 2001 CB 730.
· Form 944 Program Eases Employment Tax Reporting, Deposit Requirements for Small Employers – The IRS has issued temporary and proposed regulations (REG-148568-04; TD 9239) under Internal Revenue Code (IRC) sections 6011 and 6302 concerning employer requirements to report and pay employment taxes.
· Certain 2005 State Returns to Go to Different IRS Centers – The IRS has announced that for tax year 2005, federal income tax returns of residents in 11 states and the District of Columbia should be mailed to different service centers from last year.
· Tax Controversy Update: IRS Updates Procedures for Requesting TAMs and TEAMs – The IRS in Rev. Proc. 2006-2 has updated the procedures by which the Associate Chief Counsel’s office issues technical advice memoranda (TAMs) and technical expedited advice memoranda (TEAMs) to a director or Appeals area director.
· Recent Guidance
See attached file for details.
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LMSB Directive Renews the Focus on Examination of Parties in Intermediary Transaction Tax Shelters
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Last Updated: April 12, 2006
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Source: Deloitte & Touche USA LLP - United States (English)
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